Page 106: of Maritime Reporter Magazine (November 1996)

LEGISLATIVE UPDATE ogy (RBT) as a means to evaluate and manage safety and environ- mental hazards. For years, the

USCG experience in making deter- minations in design equivalency has pointed to a need for using

RBT. Unfortunately, for too many years the USCG dismissed this need as simply "too hard to do".

As part of the USCG's new tech- nical-regulatory paradigm, we are joining forces with other U.S. and international interests to better define, and refine RBT in order to make risk-based approaches useful marine safety and environmental protection management tools.

The USCG's Marine Safety

Evaluation Program, called "M-

STEP," is a cooperative effort involving the U.S. Navy, academia, global RBT experts and other lead- ers in the international maritime community to advance the science and utility of RBT in maritime applications.

In addition to updating and aligning technical aspects of our regulations, the USCG is stream- lining and re-engineering the regu- latory process itself. For instance, the USCG is implementing a pro- gram called the Alternate

Compliance Program (ACP), which has already begun as a pilot test.

The ACP provides owners and operators of cargo ships and tank ships in international service with an alternative to the traditional way of demonstrating compliance with applicable laws and regula- tions.

Under this program, the USCG recognizes the combination of applicable international conven- tions and rules of approved classi- fication societies as equivalent to

U.S. rules. Therefore, vessels which comply with these interna- tional conventions and approved classification society rules will be considered to be in compliance with applicable U.S. laws and reg- ulations. The Alternate

Compliance Program also elimi- nates areas of duplication where the USCG and the classification society check the same plans and inspect the same systems, thereby promoting greater efficiency in the vessel design, construction and inspection processes. ACP is just one of a "family" of new approaches to achieving marine safety and environmental protec- tion at less cost and greater effi- ciency.

Other alternative approaches are being pursued on a pilot basis by USCG field units in partner- ship with selected industry groups. One example is a

Streamlined Inspection Process (SIP). In SIP, vessel operators who develop a safety management system designed to keep their fleets in continuous regulatory compliance may enter into a safe- ty partnership with the USCG. As safety partners, qualified compa- ny personnel use USCG-approved test procedures to perform their vessels' scheduled inspections on their own, rather than in the pres- ence of a USCG marine inspector.

In SIP, the USCG adopts an "audit" culture; USCG SIP inspec- tions involve checking company records, doing limited spot checks on critical safety systems, an assessing the crew's ability to dea with shipboard emergency situa tions. This approach returns th

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